Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined deficiencies in the income tax of the petitioners and additions to tax under section 293(b) of the Internal Revenue Code of 1939 for fraud, additions to tax under section 294(d)(1)(A) of the Code for failure to file declaration of estimated tax, and additions to tax under section 294(d) (2) of the Code for substantial underestimate of estimated tax for the years and in the...
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